Appendix A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

AviTronics Integrated Solutions, LLC requests an exemption from the following

regulations as well as any additional regulations that may technically apply to the

operation of UASs contained in this request:

14 CFR Part 21, Subpart H and 14 CFR Part 91: Airworthiness Certificates, 

Manuals and Documents.

These parts establishes the procedures for the issuance of an airworthiness certificate.

While the FAA continues to work to develop airworthiness standards for UAS, we

request an exemption for the UASs operated by the applicant under following 

provisions:

The size, weight, and enclosed operational area of our UAS’s permits exemption from 

Part 21 because they meets an equivalent level of safety pursuant to Section 333 of the 

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform 

Act. Both pieces of legislation permit the FAA to exempt UASs from the airworthiness 

certificate requirement in consideration of the weight, size, speed, maneuverability, and 

proximity to areas such as airports and dense populations. Our UASs meets or 

exceeds each of the elements. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications Required. The regulation 

provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew." A UAS is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers 

or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we 

propose that documents deemed appropriate for this aircraft by the FAA will be colocated with the crew at the ground control station and available for inspection upon 

request. ln order to identify the aircraft, we propose the use of the UAS' unique

manufacturers serial number, and a contact telephone number be mounted on the UAS

on a placard of reasonable size in relation to the UAS. ln the event that a unique

manufacturers serial number is not available, the previously mentioned placard will be

affixed to the UAS consisting of the model name and number of the UAS, as well as a 

contact telephone number.

14 CFR § 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable.
14 CFR § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

on board pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a flight 

manual or equivalent (Reference Appendix C through G) be available to the crew at the 

ground station anytime the aircraft is in, or preparing for, flight.

14 CFR § 45.23 & 45.29 Display of Marks: General & Size of Marks.

These regulations provide that each aircraft must display "N" and the aircraft's

registration number in letters at least 3 inches high. The placard outlined in the 

previous paragraph will provide sufficient identifiably should someone discover the 

aircraft on the ground.

14 CFR § 91.103 Preflight Action.

Prior to every flight, the PIC will inspect the aircraft and ground station to ensure that 

they are in an airworthy condition. Any general maintenance procedures or 

replacement of consumable items outlined by the UAS manufacturer (Reference 

Appendix C through G), if applicable, will be complied with by the PlC and documented 

in the aircraft records. In no circumstance will a UAS be operated in a condition that is 

deemed, or suspected to be, unsafe. If such a determination is reached, and the 

problem cannot be remedied to the satisfaction of the PlC, the UAS will not be operated 

until consulting with the manufacturer or one of its authorized dealers to complete 

necessary repairs. We feel that due to the size, construction, and simplicity of the 

aircraft, the PIC can ensure an equivalent level of safety.

14 CFR § 91.109 Flight Instruction: Simulated Instrument Flight and Certain Flight

Tests.

The regulation provides that "No person may operate a civil aircraft that is being used 

for flight instruction unless that aircraft has fully functioning dual controls." The controls 

for a UAS do not currently have a set of fully functioning dual controls. If a UAS pilot is

being trained, the pilot performing the training would be directly supervising and could

take over the controls from the pilot in training if the need arose. This would be similar 

to the technique of a "throw-over type" control wheel in some fixed wing aircraft. We 

feel that this technique meets the intent of 91.109 and provides an equivalent level of 

safety.

14 CFR § 91.119 Minimum Safe Altitudes: General.

The regulation provides that over sparsely populated areas the aircraft cannot be

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the

typical mission of this UAS would be photography or survey of persons, vessels,

vehicles or structures it would be necessary to operate closer than 500 feet to the items

listed. Operations will only be flown over property or persons where permission has

been obtained, and careful pre-planning has been performed. Further, these UAS 

aircraft operate at a very slow airspeed, a low mass, and do not need as much space to

operate safely, as outlined in 91.119. We believe the slower speed, smaller mass and

careful pre-planning would provide an equivalent level of safety.
14 CFR § 91.121 Altimeter Settings.

The regulation provides that aircraft shall maintain cruising altitudes by reference to an

altimeter setting available within 100 nautical miles of the aircraft. The UAS will

normally be flying close to the ground, and in line of sight of the PIC and an observer. 

This line of sight operation will provide separation from other aircraft, obstructions and

terrain, and would override the use of an altimeter for such a purpose. We feel that this

will provide an equivalent level of safety.

14 CFR § 91.151 Fuel Requirements for Flight in VFR Conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to

fly after that for at least 30 minutes. We feel the intention of this paragraph it to provide 

a reasonable reserve of energy to plan for a safe landing should there be a delay in

landing. The close proximity to the ground station, the ability for both rotorcraft and

small fixed wing aircraft to land in a very small space, and the built in energy level

monitoring of the UASs we feel provide an equivalent level of safety if the flight is

planned to be completed with 20% battery energy remaining. We request an exemption

to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR Subpart E § 91.401 - 91.4171 Maintenance, Preventive Maintenance, and

Alterations.

The regulation provides that the operator is primarily responsible for maintaining the

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs

91.407 and 91.409 require that the aircraft be "approved for return to service by a 

person authorized under 43.7" after maintenance and inspection. AviTronics seeks full 

exemption from these regulations due to the fact that these sections apply to an aircraft 

with an airworthiness certificate for which AviTronics is already seeking an exemption. 

An equal level of safety will be achieved by using the inspection and maintenance 

requirements illustrated in the operator manuals (Reference Appendix C through G) 

which provide step by step instructions on Regular Maintenance, Preventive 

Maintenance, and Corrective Maintenance. The PIC will be responsible for conducting 

maintenance in accordance with the procedures. Any maintenance not covered by 

these procedures will be performed by the manufacture or a repair facility authorized by 

the manufacture.

14 CFR § 61.113 (a) & (b): Private Pilot Privileges and Limitations PIC.

Pursuant to 14 CFR § 61.113 (a) & (b), private pilots are limited to non-commercial operations. 

We can achieve an equivalent level of safety as achieved by current Regulations because our 

UAS’s do not carry any pilots or passengers. Further, while helpful, a pilot license will not 

ensure remote control piloting skills. The risks attended to the operation of AviTronics’ UASs is 

far less than the risk levels inherent in the commercial activities outlined in 14 CFR § 61, et seq.

Thus, allowing the applicant to operate UASs, meeting and exceeding current safety levels in 

relation to 14 CFR § 61.113 (a) & (b) by having the unlicensed UAS pilot directly observed by an 

individual who holds a FAA Commercial Pilot Certificate, and familiar with all facets of UAS 

operations. 
In summary, AviTronics Integrated Solutions, LLC seeks an exemption from the 

following Regulations:

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Avitronics 

Integrated Solutions, LLC requests exemption from the following Federal Aviation 

Regulations that are found under Title 14 of the Code of Federal Regulations in order to 

commercially operate small unmanned aircraft vehicles:

14 CFR § 21, Subpart H

14 CFR § 45.23 (b)

14 CFR § 45.29

14 CFR § 61.113 (a) & (b)

14 CFR § 91.7 (a)

14 CFR § 91.9 (b) (2)

14 CFR § 91.103

14 CFR § 91.109

14 CFR § 91.119

14 CFR § 91.121

14 CFR § 91.151(a)

14 CFR § 91.203 (a) and (b)

14 CFR § 91.405 (a)

14 CFR § 91.407 (a) (1)

14 CFR § 91.409 (a) (2)

14 CFR § 91.417 (a) & (b)